RoHS Lessons … with a focus on Pb

1. RoHS Lessons …with a focus on Pb David Bergman Vice President Standards, Technology and International Relations Fern Abrams, Director of Environmental Policy

2. Agenda Why RoHS? What problem are we trying to “fix”? What went wrong? Compliance Issues Technical Problems Business effects Regulatory Development Best Practices

3. WHY ROHS?

4. Concerns about Lead • 10,000 tons of SnPb solder used annually • Pb indicated as a hazardous element • Legislative action has increasingly removed it from a number of products • Gasoline • Plumbing solders and tin cans • Household paints • Bullets

5. Precautionary Principle • Substances are toxic/hazardous • Assume exposure • Prevent potential risk by banning materials • Knowledge or assessment of whether substitutes are better for the environment not part of the precautionary principle

6. Marketing/Competitive Pressures • Japanese OEMs publish timelines for “lead-free” electronics • Mainly eliminating tin-lead solder • EU hears “lead-free” is possible

7. Consumer Behavior and the Environment 100% 76% 66% 50% 45% 44% 50% 20% 1993 1998 0% Consider Environment when purchasing (Roper96) Bought product because environmentally safe or biodegradable .(Roper 96) Currently have product specifically because better for environment (98 MORI). Switched Brands after discovering harm to environment. (1999 Environmental Research Associates Inc.) Switch brands when price and quality are equal. (Roper/Cone Poll)

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9. WHAT WENT WRONG?

10. Environmental Benefits??? • Life cycle environmental assessment of banned materials was not conducted • No evidence that the substitutes have less environmental impact • Studies by the US EPA indicate that Tin-Silver-Copper solder in electronics has higher air, water, and global warming impacts than tin-lead solder due to higher operating temperatures • EU currently conducting an assessment of the costs (and hopefully benefits) of RoHS

11. EU RoHS Compliance and Enforcement RoHS Directive does not prescribe methods to determine compliance No documentation requirements No prescribed testing methods Results in legal uncertainty Exemption process is lengthy and unpredictable Ambiguity is costly in the business world

12. EU RoHS Implementation • Lacked adequate technical expertise • Lacked adequate stakeholder input • From the beginning suffered from lack of clear definitions • “put on the market” • “fixed installation” • Lack of clear definitions caused confusion and uncertainty

13. EU RoHS Compliance and Enforcement • Commission published guidance document “Frequently Asked Questions” in May 2005 • “Intended to help authorities to interpret WEEE and RoHS Directives” • Reflect Commission’s views, are not legally binding • Some member states disagree with Commission’s interpretations

14. EU RoHS Compliance and Enforcement • Lacked a clear plan for enforcement • Hexavalent Chromium is used in surface coatings • Existing test methods all measure mass per surface area NOT mass percent (mass/mass) • Result – no way for companies or enforcement authorities to assess whether RoHS Maximum Contaminant level has been exceeded

15. Reliability mode Whiskers

16. New failure mechanisms

18. Concerns from High Reliability Industry • SnPb BGA’s will outlast SAC BGA’s by a factor of 20x (or more) using a 3 Grms JG-PP PSD spectrum (0.0062 G2/Hz under first resonance) • Potentially a big problem for high reliability electronics? • Below some threshold, all SAC BGA’s will survive more than 20 years • More testing and modeling required before SAC can be widely used in high reliability electronics

20. Customer Expectationsare in conflict as products merge and markets change • Consumer-Large Market- Example DVD Player • Quality • Reliability • Product Life • Commercial- Medium Market-Broadband Communications • Quality • Reliability • Product Life • Military- Small Market-Electronics for the Soldier • Quality • Reliability • Product Life

21. Aerospace Issues • Unique to Aerospace: • Long service lifetimes • Rugged operating environments • High consequences of failure • Repair at circuit card level (mixed alloys) • Quantify reliability at design • Strict configuration control requirements (obsolescence) • Beyond Aerospace Control (most of the time): • Alloys on part terminations • Alloys on printed wiring pad finishes • Reliability tests conducted by suppliers cannot be assumed to assure reliability in aerospace applications

22. Supply Chain Disruption • Suppliers Ready for Lead-Free, But Balk at New Part Numbers • By Rob Spiegel -- Electronic News, 11/10/2004 • In a survey of component suppliers conducted by Technology Forecasters Inc. for Phoenix-based Avnet Inc., 94 percent of responding suppliers indicate they are designing components compliant with RoHS regulations, while only 53 percent indicate they intend to ascribe new part numbers to their lead-free components. • Meanwhile, a surprising 42 percent of those surveyed by the firm indicated they do not intend to create new part numbers for compliant components.

23. Supply Chain Disruption • iNEMI Wants Unique Part Numbers for Select Lead-Free BGA Parts • Rob Spiegel -- Design News, May 9, 2007 • The International Electronics Manufacturing Initiative (iNEMI), released a statement Monday indicating that the majority of its OEM and EMS members strongly support unique part numbers for BGA (ball grid array) components to differentiate any lead-free ball metallurgies other than SAC 305 or SAC 405 • iNEMI members supporting the position include 3M, Agilent Technologies Inc., Alcatel-Lucent, Analogic, Celestica, Delphi Electronics and Safety, Huawei Technologies Intel, Jabil Circuit, Microsoft, Micro Systems Engineering, Plexus, Sanmina-SCI, Solectron and Tyco Electronics.

24. Cost of RoHS Compliance- OEM 1B consumer electronics company 10K parts from 500 global suppliers 10M in design and documentation 3M in equipment upgrades 1M for soldering equipment 2M in test equipment Full time staff of 10 dedicated to directives ½ time from additional 50 people

25. Cost of RoHS Compliance- Component Distributor • “RoHS-related expenses are costing us “millions and millions of dollars” • Increasing our staff 5 to 7 percent • Additional time and money by legal • Marketing department to spread the word on a company's RoHS-compliant products • IT department time and effort

26. Cost of Compliance R&D Higher Materials Costs Supply Chain Management for in-scope and out-of-scope products Higher energy costs due to higher operating temperatures Training Need for tight inventory control and purchasing Excess and obsolete inventory Materials Declaration and compliance testing

27. Higher Material Costs

28. Higher Material Costs

29. China RoHS – Better and Worse • The Good • Items will not be added to the catalogue for substance limits until it is demonstrated to be technically feasible • Homogeneous materials adjusted to include minimum testable sizes • The Bad • Mandatory in-country testing • Inadequate lead time between regulatory development and regulatory deadlines • No exemption process

30. Regulatory Best Practices Environmental life cycle assessment of substance bans prior to implementation Transparent process Technical input Consultation with industry Clear regulations and enforcement plan from the beginning Adequate lead time for orderly implementation Clear and efficient review process Internationally harmonized regulations for a global industry

31. Thank you • David Bergman bergda@ipc.org • VP Standards, Technology & International Relations • Fern Abrams fabrams@ipc.org • Director of Environmental Policy • IPC Shanghai Office +86 21 5497 3435 • IPC Headquarters U.S. 001 847 615 7100